Textile
Chemical Management in Textiles: ZDHC, MRSL and the DPP
Chemical management in textiles: the ZDHC MRSL versus RSL, how Oeko-Tex and SVHC declarations map to Digital Product Passport fields, what to ask the dye house
Chemical compliance in textiles answers two separate questions: what was used in the dye house and what remains in the finished product. The tool for the first is the MRSL (manufacturing restricted substances list); the tool for the second is the RSL (restricted substances list) together with product test reports. The Digital Product Passport turns neither into something new; it structures the evidence you already have and places it in the right access tier.
MRSL versus RSL
| MRSL | RSL | |
|---|---|---|
| What it restricts | Chemical products used in manufacturing: dyes, finishes, auxiliaries | Substance residues in the finished product |
| Who applies it | Dye house, finishing mill, laundry | Brand, importer |
| Source | ZDHC MRSL | REACH Annex XVII, SVHC candidate list, brand or AFIRM RSL |
| Evidence | ZDHC InCheck report, Gateway conformance level, ECO PASSPORT or bluesign approved chemicals | Accredited laboratory test report, Oeko-Tex Standard 100 |
Neither replaces the other. A dye house using clean inputs can still produce residues under the wrong process conditions, and a product with a clean test result says nothing about what went into the wastewater. For the general framework of chemical declarations, see DPP for chemicals, REACH and SCIP.
The legal floor and the voluntary schemes
The legal floor is REACH: Annex XVII restrictions (azo dyes, nickel release, certain phthalates and the like), the Article 33 information duty and SCIP notification when a candidate-list SVHC is present above 0.1% by weight. The candidate list is usually updated twice a year, and your declaration has to follow. For moving targets such as PFAS, see the PFAS restriction and passport declarations.
Voluntary schemes build on that floor. Oeko-Tex Standard 100 tests the finished product or fabric against limits set by product class, and the certificate is valid for one year. ZDHC works on the manufacturing side: the Gateway chemical module lists conformant products, an InCheck report summarises how far a facility's chemical inventory conforms to the MRSL, and ClearStream reports wastewater test results. Brand RSLs generally set tighter limits and longer substance lists than REACH.
From what you already have to a passport field
| What you have | Passport field | Tier |
|---|---|---|
| Oeko-Tex Standard 100 certificate | Certificate: type, number, issuing body, expiry, scope | Public |
| Accredited laboratory RSL report | Substance of concern: substance or CAS, result, threshold, method, date | Restricted; summary public |
| Supplier SVHC declaration | SVHC above 0.1% w/w: present or absent, substance name | Public |
| ZDHC InCheck report | Wet-processing facility inventory conformance, reporting period | Restricted |
| ClearStream wastewater report | Facility-level environmental evidence | Restricted |
| Dye house and finishing list | Wet-processing supplier per style, facility identifier | Restricted |
For how the tiers are separated, see restricted data tiers and authorised access.
What to ask the dye house, and how to store it
- Record the wet-processing facilities (dye house, finishing, laundry) per style with a facility identifier; for the rest of the chain see mapping the textile supply chain.
- Ask for the facility's current InCheck report per period and note the Gateway conformance level of the chemical products used.
- Ask for an RSL test report per lot or fabric quality, or verify that the Oeko-Tex certificate actually covers that product.
- Renew the SVHC declaration at every candidate-list update.
- Never break the link between report, lot and style: field-based records instead of a PDF folder.
To standardise these requests with a contract clause and a template, see collecting DPP data from suppliers and tier-2 and tier-3 supplier transparency. For denim, where laundry chemistry is heavy, see also DPP for denim and jeans.
Trade secrets and the access tier
The dye house does not hand over its recipe, and it does not have to. What the passport declares is not the formulation but the presence of substances above threshold and the evidence of conformance. Facility identity, inventory and wastewater reports stay in the restricted tier, open to authorised buyers and auditors; the consumer sees the certificate and the SVHC declaration. See protecting trade secrets while being transparent and the textile DPP guide.
Frequently asked questions
Do I need an SVHC declaration if I have an Oeko-Tex certificate?
Yes. Oeko-Tex is a voluntary test programme; the REACH Article 33 information duty is a separate legal obligation, and the candidate list does not map one-to-one onto Oeko-Tex parameters.
Should I publish ZDHC MRSL conformance in the passport?
It is not required; facility-level evidence can stay in the restricted tier. If you publish a summary such as "MRSL-conformant wet processing", a valid report must stand behind it.
My dye house does not provide an InCheck report. What should I do?
Add a chemical evidence clause to the contract and allow time for the transition. Leave the unevidenced field as "unknown"; do not enter an estimate.
